Market Letters

Laufer Group International Duty Deferral Guide

To Our Valued Customers:

Importer Eligibility and Qualification Considerations:

There is no formal application for duty deferral, but importers will need to maintain clear and detailed records for customs review of hardship. CBP may conduct audits and assess penalties and/or monetary damages if an importer is found to be in non-compliance of the hardship threshold. Here is an excerpt from the official posting – full version can be found here.

“To qualify for this temporary postponement, an importer must demonstrate a significant financial hardship. An eligible importer’s operation must be fully or partially suspended during March or April 2020 due to orders from a competent governmental authority limiting commerce, travel, or group meetings because of COVID-19, and as a result of such suspension, the gross receipts of such importer for March 13-31, 2020 or April 2020 are less than 60 percent of the gross receipts for the comparable period in 2019. An eligible importer need not file additional documentation with CBP to be eligible for this relief but must maintain documentation as part of its books and records establishing that it meets the requirements for relief.”

  • Entries Subject to trade remedies, such as Section 301,232, and ADD/CVD, are excluded from duty deferral altogether and ineligible for any special considerations
  • No refunds will be provided on duties and taxes already paid on previously entered goods
  • Duty deferral applies to formal customs entries only
  • Importers must be on their own ACH

Next Steps:

  • Review above eligibility requirements and advise your Laufer representative you are interested in moving forward with duty deferral
  • Laufer will then run an ACE report to identify qualifying entries on your unpaid statement
  • New duty payment date will be identified
  • Approval will then need to be provided to Laufer to begin the process of deferring eligible unpaid duties.
  • You will be responsible for all record keeping of hardship eligibility and entry data required by US Customs. This written approval must be received by 3 PM on 4/20/2020 in the local time zone of your
  • Laufer CHB office for customers wishing to defer payment on statements due 4/21/2020
  • Laufer will make the necessary adjustments per entry in our operating system to accommodate the duty deferral